The Vocal PointFDA's 'solution' to SRMs in feed only increases problemsby Dan Murphy on 8/20/04 for Meatingplace.com

As a columnist who's supposed to weigh both sides of an issue, I have to pretend that this is a tough call.

On one hand, the public relations value of industry agreeing to support FDA's proposed rule banning specified risk materials (SRMs) from the feed chain is significant. Without resorting to that overused cliché — "an abundance of caution" — beef producers, packers and renderers can honestly project a positive, proactive image of an industry going to extraordinary lengths to protect the public if they line up behind FDA's proposal.

Except blocking the processing of SRMs into feed ingredients isn't a public health issue, much as a handful of professional agitators would love to have the media treat FDA's proposal as a scare story.

That reality didn't stop federal officials from positioning this new proposal strictly in terms of public health, however.

"With these additional measures, we will make a strong system even stronger," added FDA Acting Commissioner Lester M. Crawford.

Crawford's quote has an eerie echo of the "added layer of protection" theme that surrounded Homeland Security's recent rollout of the controversial biometric check-out process required of foreign visitors entering the United States. Nevertheless, it's tough to argue that government shouldn't continue to advance its measures to protect public health or ensure national security.

On the other hand, however, the economic impact of having to divert millions of tons of valuable meat and bone meal (MBM) from its current applications as feed supplements would inflict severe economic damage on the beef industry without improving public health one bit.

"As a protein ingredient, MBM is worth about $230 a ton," explains Tom Cook, president of the National Renderers Association. "As a source of energy (fuel), it's worth only $35. If this material cannot be used in livestock feed, there simply is no alternative market."

So let's officially stop pretending this ban is good idea, because the tidal wave of red ink that will wash over the industry isn't the only problem that would arise if this new prohibition goes into effect.

Despite FDA's 1997 ban on ruminant-to-ruminant feeding, bovine MBM is still allowed as an ingredient in feed for other species. That provides renderers with the economic incentive to pick up and process cattle that die before slaughter.

FDA's new proposal, however, would likely terminate the use of rendering as a disposal option for dead stock and force producers to either bury them on site or transport them to a landfill.

And you know that all those rural landfills across cattle country will just be waiting with open arms for the arrival of millions of dead animal carcasses.

Just how big of a problem is dead stock disposal? In case you haven't had the pleasure of wading through USDA's livestock mortality estimates lately, more than 4.5 million cattle (beef and dairy) die on farms or at feedlots annually. Of those, nearly 45 percent are picked up by renderers, according to a study completed this month by Informa Economics of McLean, Va.

"[But] if SRMs and/or cattle and calf mortalities cannot be used to produce livestock feed, the economic value to the rendering industry will be reduced below the cost of processing this material," the report stated. "Economics dictates this material will not be rendered."

The potential loss from sales of MBM and tallow derived from the 1.42 billion pounds of SRMs currently collected at packing plants would exceed $91 million annually, the report estimated. More importantly, those losses would be felt not only by renderers, but also by producers in the form of higher livestock feed costs and by packers in the form of higher costs for SRM segregation and disposal.

"The burden [of these proposed regulations] falls on the whole beef industry," Tom Cook, president of the National Renders Association, told Meatingplace.com. "Everyone would pay higher costs for feed and higher fees to dispose of dead and downer stock."

Added to that is an estimated $100 million-plus shortfall the rendering industry would absorb due to the loss of sales of MBM and tallow from dead stock and the loss of fees currently charged to cover the costs of transporting these carcasses to a rendering plant.

If no significant value can be gained from processing dead stock, the fees charged to dispose of them would soar, and producers would likely opt for another method of disposal.

Which brings us back to a key aspect of this discussion that carries some traction with the public: the negative environmental impact of banning SRMs in all livestock feed.

If modern, high-tech rendering were no longer an option, let's be honest: The idea that "other disposal methods" could deal with those 1.46 billion pounds of SRMs from healthy cattle at packing plants and the 4.6 million carcasses of dead stock is about as plausible as assuming that Paris Hilton will settle down and start pursuing a career any day now.

There is no regulatory oversight for on-farm burial, which leaves wide open the possibility of groundwater contamination and the spread of disease, and composting — even under the most careful, labor-intensive management — doesn't work very well for 1,400-pound animals with thick, tough hides. And keep in mind one other consideration regarding composting: The net effect of FDA's new rule could end up being exactly the opposite of what is intended — namely, keeping cattle from being exposed to BSE prions — if the material from carcasses that are composted are spread out on pastures and feed crops that are then fed to cattle.

The scenarios likely to follow imposition of FDA's proposed ban add up to a nothing less than a massive set of new problems that will likely exceed the challenges already imposed on producers, packers and renderers by the initial wave of BSE-related restrictions imposed earlier this year.

Does that mean industry should dig in and fight this new rule?

Sorry it took so long to get here, but in a word: Yes!

The bottom line message is this: No matter whether FDA bans SRMs in the feed chain or not, the amount of BSE infectivity that the beef-eating public would ever be exposed to is, as the Harvard Risk Assessment characterized it, "almost immeasurably small."

In fact, the only measurement of interest in any regulations affecting BSE prevention is its impact on public health, and in this case, the net effect on public health of banning SRMs in feed is zero.

Nobody's going to succumb to the human form of BSE because cattle are eating rendered proteins derived from other livestock. And no one's life will be spared if they're not. The current feed-chain firewall is working quite well, and that fact shouldn't be dismissed.

Secretary Thompson put it this way in trying to sell the new rule: "We cannot be content with the status quo."

Note to the secretary: Status quo left town on Dec. 23, 2003.

Dan Murphy is a freelance writer and former editor of MMT magazine based in the Pacific Northwest . His column, THE VOCAL POINT, appears in this space each Friday.

Kuru and Creutzfeldt-Jakob disease of humans and scrapie disease of sheep and goats were transmitted to squirrel monkeys (Saimiri sciureus) that were exposed to the infectious agents only by their nonforced consumption of known infectious tissues. The asymptomatic incubation period in the one monkey exposed to the virus of kuru was 36 months; that in the two monkeys exposed to the virus of Creutzfeldt-Jakob disease was 23 and 27 months, respectively; and that in the two monkeys exposed to the virus of scrapie was 25 and 32 months, respectively. Careful physical examination of the buccal cavities of all of the monkeys failed to reveal signs or oral lesions. One additional monkey similarly exposed to kuru has remained asymptomatic during the 39 months that it has been under observation.

There is substantial scientific evidence to support the notion that bovine spongiform encephalopathy (BSE) has contaminated human beings, causing variant Creutzfeldt-Jakob disease (vCJD). This disease has raised concerns about the possibility of an iatrogenic secondary transmission to humans, because the biological properties of the primate-adapted BSE agent are unknown. We show that (i) BSE can be transmitted from primate to primate by intravenous route in 25 months, and (ii) an iatrogenic transmission of vCJD to humans could be readily recognized pathologically, whether it occurs by the central or peripheral route. Strain typing in mice demonstrates that the BSE agent adapts to macaques in the same way as it does to humans and confirms that the BSE agent is responsible for vCJD not only in the United Kingdom but also in France. The agent responsible for French iatrogenic growth hormone-linked CJD taken as a control is very different from vCJD but is similar to that found in one case of sporadic CJD and one sheep scrapie isolate. These data will be key in identifying the origin of human cases of prion disease, including accidental vCJD transmission, and could provide bases for vCJD risk assessment.

Dormont*, and Jean-Philippe Deslys* et al, that The agent responsiblefor French iatrogenic growth hormone-linked CJD taken as a control isvery different from vCJD but is similar to that found in one case ofsporadic CJD and one sheep scrapie isolate;

http://www.pnas.org/cgi/content/full/041490898v1

Here is the link for EFSAs most recent GBR reports

You will find the final BSE risk assessments for the USA, Canada, Mexico, South Africa (all in category III)and Norway and Sweden (both in category II) and Australia (category I).For each country there is a summary (1 page) - a short report (6 pages) and they seem to have trouble with the links for the full reports (15-20 pages) but they are 'working on it'. The links to these more complete working group reports (referred to as "annex") are usually found on page 5 of the 6-page reports.I have until now only managed to get the link of the long report for the USA.

USA

EFSA Scientific Report on the Assessment of the Geographical BSE-Risk (GBR) of the United States of America (USA)Publication date: 20 August 2004

short report USA (6 pages)

Annex = full report, 17 pages

snip......EFSA concludes that the current GBR level of USA is III, i.e. it is likely but not confirmed that domestic cattle are (clinically or pre-clinically) infected with the BSE-agent. As long as there are no significant changes in rendering or feeding, the stability remains extremely/very unstable. Thus, the probability of cattle to be (pre-clinically or clinically) infected with the BSE-agent persistently increases__

MEXICO

...EFSA concludes that the current geographical BSE risk (GBR) level is III, i.e. it is likely but not confirmed that domestic cattle are (clinically or pre-clinically) infected with the BSE-agent. The GBR is likely to increase due to continued internal and external challenge, coupled with a very unstable system. ...

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CANADA

...EFSA concludes that the current GBR level of Canada is III, i.e. it is confirmed at a lower level that domestic cattle are (clinically or pre-clinically) infected with the BSE-agent. As long as the system remains unstable, it is expected that the GBR continues to grow, even if no additional external challenges occur.

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SOUTH AFRICA

...EFSA concludes that the current GBR level of South Africa is III, i.e. it is likely but not confirmed that domestic cattle are (clinically or pre-clinically) infected with the BSE-agent. As long as there are no serious changes in rendering or feeding, the stability remains very unstable. Thus, the probability of cattle to be (pre-clinically or clinically) infected with the BSE-agent persistently increases even if no additional external challenges occur. ..

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SWEDEN

...EFSA concludes that the current geographical BSE-risk (GBR) level is II, i.e. it is unlikely but can not be excluded that domestic cattle are (clinically or pre-clinically) infected with the BSE-agent. The Swedish BSE/cattle system is now regarded to be optimally stable. This implies that the probability of cattle to become newly infected with the BSE-agent is extremely low.

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NORWAY

...EFSA concludes that the current geographical BSE-risk (GBR) level is II, as it is unlikely but can not be excluded that domestic cattle are (clinically or pre-clinically) infected with the BSE-agent. The Norwegian BSE/cattle system is now regarded to be very stable....

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AUSTRALIA

...EFSA concludes that the current GBR Australia level is I, i.e., it is highly unlikely that domestic cattle are (clinically or pre-clinically) infected with the BSE-agent. As long as the possibility of cross-contamination exists and there are no serious changes in rendering, the system will continue to be very unstable. Thus, the possibility of cattle being (pre-clinically or clinically) infected with the BSE-agent will remain at a low level.

GBR assessments:There were some problems with the links for the full "working group reports"- Here are all the links for the 7 countries GBR-assessments published on August 20th.Best regardsKarin Irgens__USA